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ALPS Series Trust

1290 Broadway, Suite 1000

Denver, Colorado 80203

    January 28, 2022

    VIA
    EDGAR

    Ms. Samantha Brutlag

    Division of Investment Management

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

 Re:	 ALPS Series Trust (the “Registrant”), on behalf of its series, Seven Canyons Strategic
                                                                   Global Fund and Seven Canyons World Innovators Fund (each, a “Fund” and collectively the “Funds”);
                                                                   Registration Nos. 333-183945 and 811-22747

Dear
Ms. Brutlag:

On behalf of the Registrant, set
forth below are the Registrant’s responses to comments received from the staff of the Division of Investment Management regarding
Post-Effective Amendment No. 94 (“PEA 94”) to the Registrant’s registration statement under the Securities
Act of 1933, as amended (the “1933 Act”), and Post-Effective Amendment No. 95 under the Investment Company Act of 1940, as
amended (the “Investment Company Act”), filed pursuant to Rule 485(a) on November 24, 2021, with respect to each Fund.

In connection with this response
letter, and on or around January 28, 2022, the Registrant anticipates filing, pursuant to Rule 485(b), a new post-effective amendment
to the Registrant’s registration statement under the 1933 Act, which is expected to include (i) changes to PEA 94 in response to
the Staff’s comments, (ii) certain other non-material information; and (ii) certain other required exhibits.

Set forth in the numbered paragraphs
below are the Staff’s oral comments provided January 4, 2022 to PEA 94, accompanied by the Registrant’s responses to each
comment. Capitalized terms not otherwise defined herein shall have the meanings given to them in PEA 94.

 1. Staff Comment: Staff comments with respect to one Fund apply
to each Fund.

Registrant’s
Response: Comment complied with.

 2. Staff Comment: Please confirm supplementally that the expense
limitation agreement with respect to each Fund may not be terminated by the Funds’ investment adviser at any point during the one-year
period commencing on the date of the Funds’ prospectus.

Registrant’s
Response: Registrant confirms that the expense limitation agreement with respect to each Fund may not be terminated by the Funds’
investment adviser during the one-year period commencing on the date of the Funds’ prospectus.

 3. Staff Comment: Please provide each Fund’s completed
fee table and expense example at least one week prior to the date of effectiveness.

Ms. Samantha Brutlag

January 28, 2022

Page 2

Registrant’s
Response: Completed fee tables and expense examples for each Fund are attached as Exhibit A hereto.

 4. Staff Comment: Please revise the narrative in each Fund’s
“Performance Information” section to include the date that the Fund changed its investment strategy.

Registrant’s
Response: Comment complied with. Without necessarily agreeing with the necessity to include such disclosure, the below sentence
has been added immediately prior to the penultimate sentence of the narrative in each Fund’s “Performance Information”
section:

“Additionally,
the Fund modified its investment strategy on January 28, 2022.”

 5. Staff Comment: Please confirm supplementally that the Funds’
provided at least sixty (60) days’ notice to shareholders of the changes to the Funds’ respective investment strategies.

Registrant’s
Response: Registrant confirms that supplements to the Funds’ summary prospectus, statutory prospectus, and statement of
information detailing the Funds’ revised principal investment strategies disclosures were filed with the Commission via EDGAR on
November 24, 2021.

* * * * *

If you have any questions or further
comments, please contact Peter Schwartz, counsel to the Registrant, at (303) 892-7381.

	/s/ Patrick
Rogers

	Patrick Rogers

	Secretary of ALPS
Series Trust

cc:	Peter H. Schwartz, Esq., Davis Graham & Stubbs
LLP

Ms. Samantha Brutlag

January 28, 2022

Page 3

Exhibit
A

Seven Canyons Strategic Global Fund

Fees and Expenses of the Fund

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund.

Shareholder
Fees (fees paid directly from your investment)

    Investor Class

    Maximum sales
    charge (Load) imposed on purchases

    None

    Redemption
    Fee (as a percentage of amount redeemed, if you sell or exchange your shares within 60 days of purchase)

    2.00%

    Exchange Fee

    None

    Maximum Account
    Fee

    None

Annual
Fund Operating Expenses

(expenses that you pay each year as a percentage of the value of your investment)

    Investor Class

    Management
    Fees

    0.70%

    Distribution
    and Service (12b-1) Fees

    None

    Total Other
    Expenses

    0.59%

    Acquired Fund
    Fees and Expenses

    0.19%

    Total Annual
    Fund Operating Expenses

    1.48%

    Fee Waiver
    and Expense Reimbursement (1)

    (0.34)%

    Total Annual
    Fund Operating Expenses After Fee Waiver/Expense Reimbursement (1)

    1.14%

 (1) Seven Canyons Advisors, LLC, the Fund’s investment adviser (the “Adviser”), has contractually
agreed to limit the amount of the Fund’s total annual fund operating expenses (exclusive of interest, dividend expense on short
sales/interest expense, taxes, brokerage commissions, other investment related costs, acquired fund fees and expenses, and extraordinary
expenses such as litigation and other expenses not incurred in the ordinary course of business) to an annual rate of 0.95% of the Fund’s
average daily net assets. This agreement is in effect through at least January 31, 2023, and will automatically continue upon annual approval
by the board for successive twelve-month periods unless (i) it is terminated earlier by the Board of Trustees, or (ii) the Adviser provides
at least 30 days written notice of its non-continuance prior to the end of the then effective term. The Adviser will be permitted to recover
expenses it has borne through the agreement described above (whether through reduction of its management fee or otherwise) only to the
extent that the Fund’s expenses in later periods do not exceed the lesser of (1) the contractual expense limit in effect at the
time the Adviser waives or limits the expenses or (2) the contractual expense limit in effect at the time the Adviser seeks to recover
the expenses; provided, however, that the Fund will not obligated to pay any such deferred fees or expenses more than three years after
the date on which the fee and expense was reduced, as calculated on a monthly basis.

Example

This example is intended to help you compare the costs
of investing in the Fund with the cost of investing in other mutual funds. The example assumes that you invest $10,000 in the Fund for
the time periods indicated and then redeem all of your shares at the end of those periods. The example also assumes that your investment
has a 5% return each year and that the Fund’s operating expenses remain the same. The example takes into consideration the agreement
by the Adviser to waive fees and reimburse expenses for the contractual period only.

Ms. Samantha Brutlag

January 28, 2022

Page 4

Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1 Year

    3 Years

    5 Years

    10 Years

    Investor Class

    $	116

    $	434

    $	775

    $	1,737

Seven Canyons World Innovators Fund

Fees and Expenses of the Fund

This table describes the fees and expenses that you
may pay if you buy, hold, and sell shares of the Fund.

Shareholder
Fees (fees paid directly from your investment)

    Investor Class

    Institutional
    Class

    Maximum sales
    charge (Load) imposed on purchases

    None

    None

    Redemption
    Fee (as a percentage of amount redeemed, if you sell or exchange your shares within 60 days of purchase)

    2.00%

    2.00%

    Exchange Fee

    None

    None

    Maximum Account
    Fee

    None

    None

Annual
Fund Operating Expenses

(expenses that you pay each year as a percentage of the value of your investment)

    Investor Class

    Institutional
    Class

    Management
    Fees

    1.50%

    1.50%

    Distribution
    and Service (12b-1) Fees

    None

    None

    Total Other
    Expenses

    0.38%

    0.38%

    Acquired Fund
    Fees and Expenses

    0.00%

    0.00%

    Total Annual
    Fund Operating Expenses

    1.88%

    1.88%

    Fee Waiver
    and Expense Reimbursement (1)

    (0.13)%

    (0.33)%

    Total Annual
    Fund Operating Expenses After Fee Waiver/Expense Reimbursement (1)

    1.75%

    1.55%

Ms. Samantha Brutlag

January 28, 2022

Page 5

 (1) Seven Canyons Advisors, LLC, the Fund’s investment adviser (the “Adviser”), has contractually
agreed to limit the amount of the Fund’s total annual fund operating expenses (exclusive of interest, dividend expense on short
sales/interest expense, taxes, brokerage commissions, other investment related costs, acquired fund fees and expenses, and extraordinary
expenses such as litigation and other expenses not incurred in the ordinary course of business) to an annual rate of 1.75% and 1.55% of
the Fund’s average daily net assets for the Investor Class and the Institutional Class, respectively. This agreement is in effect
through at least January 31, 2023, and will automatically continue upon annual approval by the board for successive twelve-month periods
unless (i) it is terminated earlier by the Board of Trustees, or (ii) the Adviser provides at least 30 days written notice of its non-continuance
prior to the end of the then effective term. The Adviser will be permitted to recover, on a class-by-class basis, expenses it has borne
through the agreement described above (whether through reduction of its management fee or otherwise) only to the extent that the Fund’s
expenses in later periods do not exceed the lesser of (1) the contractual expense limit in effect at the time the Adviser waives or limits
the expenses or (2) the contractual expense limit in effect at the time the Adviser seeks to recover the expenses; provided, however,
the Fund will not be obligated to pay any such deferred fees or expenses more than three years after the date on which the fee and expense
was reduced, as calculated on a monthly basis.

Example

This example is intended to help you compare the costs
of investing in the Fund with the cost of investing in other mutual funds. The example assumes that you invest $10,000 in the Fund for
the time periods indicated and then redeem all of your shares at the end of those periods. The example also assumes that your investment
has a 5% return each year and that the Fund’s operating expenses remain the same. The example takes into consideration the agreement
by the Adviser to waive fees and reimburse expenses for the contractual period only.

Although your actual costs may be higher or lower,
based on these assumptions your costs would be:

    1 Year

    3 Years

    5 Years

    10 Years

    Investor Class

    $	178

    $	578

    $	1,003

    $	2,187

    Institutional Class

    $	158

    $	559

    $	985

    $	2,171